Parking Enforcement Program Audit Checklist€¦ · Appendix B1 –Parking Enforcement Program...

APPENDIX B1 Parking Enforcement Program Audit Checklist

Appendix B1 –Parking Enforcement Program Audit Checklist

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This document can serve two purposes for the City of Boise. Initially, this checklist can be used by program managers as a tool for the refinement of the

current parking enforcement program. This document was originally designed to be used as a checklist to support the auditing of various aspects of a

municipal parking enforcement program. For each audit standard, auditors can note whether or not the program complies, or if the result is unclear, and

can also add comments or observations supporting their conclusion. Since this document was created based on several communities, it is recommended

that this tool be customized to the Boise parking enforcement program and used on an on-going basis.

A. Ordering and Control of Citation Stock

Blank citation stock—whether for handwritten citations or for handheld issuance devices - is an often neglected but critical aspect of parking programs.

Blank citations are also potential receivables. Therefore it is essential that the enforcement program always have an adequate supply of citation stock. In

addition, inadequate controls on inventory can allow blank citations to be used for fraudulent purposes. The following are some of the basic checks that

apply to this component.

# Standard Yes No Unclear Observation/Comments/Action Taken

A.1 Are there written procedures governing the ordering,

acceptance, distribution and tracking of citation stock?

A.2 Do the procedures govern all necessary aspects of the

ordering, delivery, acceptance and storage processes?

A.2.1 Is there an inventory tracking system that tracks

additions to, withdrawals from, and the current citation

inventory?

A.2.1.1 Is the tracking system maintained on an electronic

spreadsheet or database to avoid mathematical error?

A.2.1.2 Does the tracking system cover distribution to

subordinate levels, i.e., individual enforcement locations

and individual officers?

A.2.2 Are there specific “trigger points”, i.e., inventory levels

that when reached, trigger the start of the reorder

process with sufficient lead time to insure that

inventories are not exhausted prior to delivery of the new

order?

A.2.3 Is responsibility for ordering stock assigned to a senior

manager who understands the importance of this

function?


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A.2.4 Does the reordering process include adequate time and

instructions to incorporate updates of the citation form

to include any recent changes in program business rules

or boilerplate information (mail-in payment address,

customer service phone numbers, etc.)?

A.2.5 Are previous orders for citation stock filed for easy

access and (as applicable) do they contain the number

ranges of the previous orders so that number ranges are

not duplicated in subsequent orders?

A.2.6 Are deliveries of new citation stock both logged against

the current order and updated to the inventory tracking

system?

A.2.6.1 Is there a written quality control check list against which

the new stock is immediately compared to the written

specifications in the purchase order?

A.2.7 Is citation stock stored in a secure, locked room or

closet?

A.2.8 Is ticket stock periodically inventoried and compared to

the tracking system and any discrepancies investigated

and reconciled?

A.3 Do the procedures govern all necessary aspects of

distributing citation stock to the enforcement staff?

A.3.1 As appropriate based on the number of agencies and

individuals who issue citations, are there intermediate

distribution points (i.e., from central storage to the

responsible department or the Parking Enforcement

office)?

A.3.2 If the program uses intermediate storage locations, are

they also be subject to a periodic inventory review

process?

A.3.3 Are such distributions properly logged to the inventory

tracking system?

A.3.4 At the officer level, is distribution of blank ticket books

logged to the tracking system?


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A.3.5 Periodically, are the number of blank books/citations

distributed to enforcement offices and individual officers

compared to issued tickets updated to the citation

processing system or otherwise voided?

A.3.5.1 Are any discrepancies between citations distributed to

offices/individual officers and citations updated to the

system investigated and reconciled?

A.4 The control of citation stock for handheld issuance

devices can present some additional challenges. While

some devices may continue to rely on stock with pre-

printed citation numbers (which can be handled in the

same manner as discussed above for handwritten

citations), most handheld systems in use today generate

an automatically incremented citation number at the time

of issuance. Is generation of citation numbers carefully

controlled and monitored?

A.4.1 At the macro level, does the handheld system exercise

control over the range of citation numbers assigned?

A.4.1.1 Is the range of numbers used for handheld devices

separate and distinct from the numbers used for

handwritten citation stock?

A.4.2 Whether from a central server or from a local base

station linked to the handheld docking cradles, are

distinct number ranges assigned to individual handheld

devices?

A.4.3 Do base stations (if applicable) and individual handhelds

have “trigger” points so that when some set percentage

of the assigned number range has been assigned/issued,

a new block of numbers can be assigned?

A.4.4 As with handwritten citations, are periodic audits

performed to insure that number ranges are being fully

used? (While not a problem on individual handhelds,

some older systems allow number ranges to be stalled at

the base station and remain unassigned to handhelds.)


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A.4.5 If handhelds are not permanently assigned to specific

officers, is a daily log kept of which officers use which

handheld devices?

A.4.6 Do the handheld devices require the officer to sign on to

the device at the start of a shift using a secure password?

A.4.6.1 Is the date and time of violation printed on each citation

automatically generated by the handheld device?

A.4.6.2 Is the accuracy of the devices’ time and date regularly

verified by the supervisor/manager?


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B. Control and Processing of Issued Citations

Once issued, a citation becomes a receivable whose value may increase (with late penalties, for example) or decrease (dismissals or reductions in the hearing

process, payments, etc.) It is critical, therefore, that all proper actions be taken to both provide due process to the recipient and achieve a payment or other

satisfactory outcome for the program, and that all transactions relative to each citation be tracked throughout the citation’s life cycle. Key issues to be

addressed include:


B.1 Are there written procedures governing the control of

issued citations and their update to the system?

B.2 Are all issued citations uploaded to the processing

system database or otherwise accounted for?

B.2.1 For handwritten citations, is there a detailed process for

controlling batches of issued citations? Ideally, this

should be a three point process in which counts of

citations are made and reconciled at the appropriate

enforcement office where the citations are first batched,

at the data entry point, and after the citations have

been updated to the database.

B.2.1.1 For handheld citations, is there a procedure to ensure

that all handhelds used during the prior shift are

cradled and the tickets uploaded to the processing

system?

B.2.2 Does the processing system have sufficient quality

control edits to ensure that all required fields have been

completed by the officer and that the data in critical

fields is correctly formatted?

B.2.3 Does the parking program follow a procedure for

controlling and tracking voided citations, including the

issuing officer, date and the reason the citation was

voided. This can be done within the processing system

or separately?

B.2.3.1 In addition, is there a process to periodically review

individual officer’s void history to identify those with

excessive numbers of voids?


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B.2.4 With regards to “courtesy warnings”, are individual

officer’s warnings ever checked against the database to

see that a warning (instead of a citation) was

appropriate?

B.2.4.1 If a PCO has issued inappropriate warnings, is a

notation made in his/her record and follow-up training

conducted?

B.3 Since the vast majority of parking citations are issued

when the driver is not present, the responsible party

(usually the registered owner) must be identified after

the fact. Does the program have an effective process

for identifying the responsible party and his/her mailing

address for each citation issued?

B.3.1 Does the program have the necessary relationships and

data exchanges (either directly or through a vendor)

with the appropriate Departments of Motor Vehicles to

identify the registered owners of vehicles with in-state,

out-of-state plates?

B.3.2 Does the program have a process for obtaining renter

information from rental companies whose vehicles are

cited?

B.3.3 Does the processing system have the ability to update

name and address information gained from third

parties such as rental companies and National Change

of Address (NCOA)?

B.3.4 When notices are returned as undeliverable, does the

program have the ability to prevent mailings to the bad

address and obtain and update new, current addresses

from the USPS and third party vendors?

B.3.5 Does the processing system provide regular reports on

the percentage of citations for each category (in-state,

out-of-state, etc.) for which a responsible party name

and address is obtained?

B.3.5.1 Are deviations from the normal rates investigated?


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B.3.6 Are citations for which a name and address are not

obtained (no hits) flagged by the system and scheduled

for a follow-up DMV inquiry?

B.4 A fair and accessible adjudication function is both

legally required and critical to maintaining the

program’s integrity and support. Does the program,

and the processing system, provide such an

adjudicatory capability?

B.4.1 Are there written guidelines regarding the timeframes

under which citations are eligible for the various types

of reviews/hearings offered to respondents?

B.4.2 Does the processing system automatically enforce

hearing eligibility rules by edits and security provisions?

B.4.3 Is the scheduling of a review or hearing subject to

governing law or ordinance?

B.4.3.1 Does a scheduled review or hearing suspend noticing

and the imposition of late penalties?

B.4.4 Does the processing system allow for the updating of

citation records with the results of reviews/hearings and

any appropriate modifications to the balance due on

the citation?

B.4.5 Are there provisions for defaulting (to the extent

allowed by law) respondents who do not appear for

hearings. (A default is a legal acceptance of liability for

the fine.)?

B.4.6 Does program staff have access to the data necessary

to process administrative claims (i.e., claims of broken

meter, missing sign, etc.)?

B.4.7 In order to allow proper monitoring of the adjudication

function, does the program maintain or is it able to

produce analyses of decision patterns for the program

overall and by hearing examiner/judge, issuing officer,

and regulation?


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B.4.8 On a daily basis, does staff perform a reconciliation of

all adjudicatory decisions rendered and then update to

the citation database to insure that citation balances

are being adjusted appropriately?

B.4.9 Do materials provided by the program (on the citation

itself, on notices, hearing decisions, program handouts,

web-site, etc.) fully and clearly inform citation recipients

of their rights and obligations, and how to access

service?

B.5 Once issued, are citations processed through their life

cycle in a timely manner in compliance with applicable

laws? (Ideally, this is largely done on an automated

basis by the citation processing software.)

B.5.1 Is the citation life cycle documented and is the system

audited on a regular basis to ensure that citations are

being processed in compliance with it?

B.5.2 Are late penalties applied to eligible citations at the

proper time and in the proper amount?

B.5.3 For delinquent citations, are notices mailed on a timely

basis?

B.5.4 When mail is returned as undeliverable, are the citation

records flagged so that a more current address can be

sought?

B.5.5 When appropriate—such as pending a scheduled

hearing or while a claim is being researched—are other

processing actions (such as notices) suspended?

B.5.6 At a minimum, is the processing system able to

generate exception reports for citations that have been

in a suspended status for an excessive number of days?

B.5.7 How often are such reports run and reviewed?

B.5.8 Does the system have the ability to identify citations

that have aged into a new status, such as eligibility for

referral to a collection agent or write-off?

B.5.9 Does the processing system automatically carry out the

appropriate “next action”?


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B.6 Are citation payments processed in such a manner that

ensures complete, timely and accurate application of all

payments?

B.6.1 Does the program have a written security policy which

is provided to all new employees?

B.6.2 Are employees required to acknowledge receipt and

familiarity with the security policy in writing and is such

documentation included in the employee’s personnel

file?

B.6.3 Does access to the processing system require sign-on

with a User ID and a password?

B.6.4 Are user ID’s controlled by a management level

employee and documented in writing, with the

documents stored securely?

B.6.5 Are users required to change passwords on a regular

basis (no less frequently than every 60 days)?

B.6.6 Does the system provide various levels of access—

based on job requirements, such as read only, routine

update, and restricted access to sensitive transactions?

B.6.7 Does the processing system provide a complete audit

trail for all transactions which directly or indirectly

impact the balance of a citation or the program’s ability

to collect outstanding fines?

B.6.8 Do the audit trails include the User ID of the person

performing the transaction and the date and time of

the transaction?

B.6.9 Does the processing system prevent the deletion of any

transaction record or citation and plate records? If a

transaction must be reversed (e.g., an incorrectly

entered payment) the system should reflect the original

transaction, a reversal transaction, and the corrected

transaction.


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B.6.10 Does the system (or the server/network which supports

it) provide sufficient levels of back-up so that program

data is always secure?

B.6.11 Does the program have a written disaster

recovery/business continuity plan which is tested on at

least an annual basis?

B.6.12 Are ongoing or intermediate tasks which support the

larger DR plan (such as regular database backups)

carefully monitored and documented?


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C. Pursuit of Delinquent Citations

While a high percentage of citations are paid in a timely manner, either after issuance or following a hearing, many require addition action. These generally

fall into three categories: in-house pursuit of delinquent accounts, booting and towing of “scofflaw” vehicles, and use of third party collection firms. Each

has its own requirements.

C.1 Are in-house collection efforts sufficiently robust to

insure that citations are not unnecessarily assigned to

collections and therefore subject to commission?

C.1.1 Are the citation life cycles (for normal citations, fleets,

rentals, etc.) documented and understood by all

program staff?

C.1.2 As noted above, does the program have an effective

means of obtaining name and address information on

the party responsible for each citation in a time manner

after issuance, as well as the ability to obtain updated

addresses for citations which result in returned mail?

C.1.3 Does the processing system automatically add late

penalties and generate delinquent notices according to

the approved life cycle(s)?

C.1.4 If required or permitted by law or ordinance, does the

system support different life cycles for citations issued

to different categories of respondent (in-state, out-of-

state, rental, government, etc.)?

C.1.5 Does the system support generation of all required

notices, as well as additional collection notices prior to

assignment to collection agents?

C.1.6 If allowed by state law, is the program’s in-state DMV

informed of registered owners with sufficient delinquent

citations to qualify for registration non-renewal or denial

of other privilege?


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C. 2 Does the program utilize a strong, accountable

booting/towing program by which scofflaw vehicles

identified on the street can be immobilized or

impounded until outstanding fines are paid?

C.2.1 Does the program have a dispatching system which

tracks all authorized boot and tow assignments and

actual boots and tows or reasons why the assigned

action was not carried out? Ideally, this system should

be automated.

C.2.2 Does the system have strict procedures and

operational/technical support so that booted and towed

vehicles cannot be released without payment of all fines,

penalties and boot/tow/storage fees?

C.2.3 (If appropriate) On a daily basis, are boot releases

reconciled to boots authorized, boots still on the street,

and vehicles not found (“Gone on arrivals”)?

C.2.4 On a regular basis--no less than monthly, Is the tow lot

inventory report reconciled to vehicles physically on the

lot?

C.2.5 Does the tow lot inventory system allow for the aging of

tows so that un-redeemed tows are auctioned in a timely

manner and auctioned as appropriate?

C.2.6 Whether or not a private tow vendor is used, is the tow

operation audited on a regular basis to insure that the

correct tow and storage fees are collected?

C.2.7 If a vendor is used, is it responsible for any citation fines

and fees it fails to collect prior to release of a vehicle?

C.3. Are third party collection firms used as appropriate and

with proper controls and safeguards?

C.3.1 Is the assignment of cases to the collection agent based

on documented criteria and based on time- or event-

driven criteria (i.e., a set number of days since issuance or

since a particular in-house notice or the lapse of a DMV

registration hold)?


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C.3.2 Are citations only assigned after the completion of all in-

house collection actions with a reasonable expectation of

success?

C.3.3 Are citations assigned on a timely, regular schedule, such

as monthly or quarterly?

C.3.4 When cases are assigned, is the processing system

updated with relevant information, particularly the date?

C.3.5 Are assigned citations flagged so that in-house noticing

is suspended?

C.3.6 Does the agreement with the collection agent specify

particular collection actions that will be taken and a set

timeframe for completing those actions?

C.3.7 Does the agreement with the collection agent specify

City rights such as the right to recall cases at any time,

and the right to assign cases to another collection agent

following recall?

C.3.8 Is there a set schedule on which the collection agent

remits payments to the parking operator? While daily

remittance might not be practical, it should be no less

than weekly.

C.3.9 Does the parking staff have a documented process in

place to immediately reconcile all payments from the

collection agent and investigate/reconcile any payments

that cannot be applied?

C.3.10 Does the system provide regular reports on the inventory

of cases held by the collection agent, including aging by

date of assignment, so that the collection agent’s

effectiveness can be evaluated?

C.3.11 Does the program have an ongoing process for “salting”

payments on assigned cases to insure that the collection

agent applies and forwards all payments in a complete

and timely manner?

C.3.12 Does the City regularly audit the records of the collection

agent, not only to insure that all payments are being


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forwarded in a timely and accurate manner, but also to

insure that all contractually required collection actions

are being taken and documented?

C.3.13 As part of its citation life cycle, does the City have write-

off criteria? Generally, when cases are returned or

recalled from the collection agent, write-off is the

appropriate action. Otherwise, the potential value of the

program’s accounts receivable will be overestimated and

possibly misinterpreted.


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D. MONITORING AND AUDITING OF PARKING PERMIT OPERATIONS

In the municipal environment parking permits are often used to control parking in designated lots and structures or to limit parking in residential

neighborhoods whose quality of life is threatened by nearby parking generators. Because of the privileges they convey, and sometimes the cost, permits can

be valuable commodities and must be safeguarded much like cash. In addition, it is vital that they be sold/issued in strict accordance with program rules

and only to those who are eligible. Key elements to be audited include:


D.1 Are there written procedures governing the ordering,

receipt, distribution, and sale of permits?

D.2 Do the procedures govern all necessary aspects of the

ordering/receipt/sale process?

D.2.1 Is there an inventory tracking system that tracks additions

to, withdrawals from, and the current permit inventory?

Ideally this should be maintained on an electronic

spreadsheet to avoid mathematical errors.

D.2.2 Are there written “trigger points”, i.e., inventory levels

that when reached, trigger the start of the reorder

process with sufficient lead time to insure that inventories

are not exhausted prior to delivery of the new order?

This is particularly important for permits which generally

expire on a set schedule with a change in colors used to

differentiate between current and out-dated permits.

D.2.3 Is responsibility for ordering stock vested in a manager

who understands the importance of this function?

D.2.4 Is permit stock designed to discourage counterfeiting

(such as reflective decals) and to facilitate easy

verification by enforcement staff (large numbers or letters

for permit districts/structures, and bold colors that readily

distinguish current permits from old?.

D.2.5 In addition, is each permit for a type/district numbered

consecutively so that inventories can be controlled and

fraudulent use of lost/stolen permits can be minimized?

D.2.5 Does the documented reordering process include

adequate time and instructions to incorporate any


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desired changes in color or fraud deterrent features, and

delivery dates that support the renewal cycle?

D.2.6 Are previous orders for permit stock filed for easy access

and (as applicable) contain the number ranges of the

previous orders so that number ranges are not duplicated

in subsequent orders?

D.2.7 Are deliveries of new permit stock both logged and

reconciled against the current order and updated to the

permit inventory tracking system?

D.2.8 In addition, is there a written quality control check list so

the new stock can immediately be compared to the

written specifications in the purchase order?

D.2.9 Is unissued permit stock stored in a secure, locked room

or closet?

D.2.10 Is the permit stock periodically inventoried and compared

to the tracking system and any discrepancies reconciled?

D.3 Do the procedures govern all necessary aspects of

distributing permits to the sales staff?

D.3.1 As appropriate based on the number of locations and

individuals who sell permits, are there intermediate

distribution points (e.g.,, from central storage to the sales

locations)?

D.3.2 If the program uses such intermediate storage locations,

are they subject to a periodic inventory process?

D.3.4 Are any such distributions properly logged to the

inventory tracking system?

D.3.5 At the cashier or customer service representative level,

are distributions of permits logged and reconciled each

day, with the number of permits sold and those still on

hand equaling the number distributed at the start of

business?

D.3.6 Are permit sales also incorporated into the daily cashier

balancing process?

D.3.7 If permits sales are tracked within the citation processing

system or another automated tracking system, is that


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system periodically audited for gaps in the permits sold,

and missing permit numbers investigated?

D.4 Are permits sold in compliance with eligibility

standards and other business rules?

D.4.1 Are written guidelines regarding eligibility to buy permits,

permit costs, and permit duration and format available to

the public?

D.4.2 Is all staff involved in the sale of permits, otherwise

serving permit customers, and enforcing permit

regulations fully familiar with the business rules and

eligibility guidelines governing the program?

D.4.3 Does the process for opening a permit account include a

written application and provision of documentary

evidence as required by the program guidelines? Such

documentation usually includes proof of residence at an

eligible address (such as a utility bill) and proof that the

permitted vehicle is registered at that address.

D.4.4 As an aid to the confiscation of improperly used permits,

do the program rules state—to the extent legally

permitted—that issued permits remain the property of

the program and can be confiscated by enforcement

personnel if used contrary to program rules?

D.4.5. Are copies of completed applications and supporting

documentation filed for at least as long as the account is

active plus some reasonable period?

D.4.6 Do program managers periodically audit permit sales to

see that the sampled permits/accounts comply with

program guidelines with regard to residence, vehicle

registration and number of permits issued (as

applicable)?

D.4.7 If renewal notices are mailed to account holders, is this

done with ample lead time to insure that mail orders can

be processed such that new permits can be received and

displayed by the required date(s)? Failure to do so can

result in laborious work-arounds that can be abused.


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D.4.8 If supported by the enforcement handheld devices, are

automated lists/files of permits reported as lost or stolen

periodically downloaded to the handhelds so that officers

can screen permits on vehicles for possible abuse?

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